COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report Country Chapter on the rule of law situation in Sweden Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report The rule of law situation in the European Union
Date: 2022-07-13
Institutions: European Commission, Secretariat-General
Subjects: Sweden, coronavirus disease, corruption, democracy, epidemic, independence of the judiciary, infringement of EU law, pluralism in the media, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Luxembourg, 13.7.2022  SWD(2022) 527 final  COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report        Country Chapter on the rule of law situation in Sweden Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report          The rule of law situation in the European Union {COM(2022) 500 final} - {SWD(2022) 501 final} - {SWD(2022) 502 final} - {SWD(2022) 503 final} - {SWD(2022) 504 final} - {SWD(2022) 505 final} - {SWD(2022) 506 final} - {SWD(2022) 507 final} - {SWD(2022) 508 final} - {SWD(2022) 509 final} - {SWD(2022) 510 final} - {SWD(2022) 511 final} - {SWD(2022) 512 final} - {SWD(2022) 513 final} - {SWD(2022) 514 final} - {SWD(2022) 515 final} - {SWD(2022) 516 final} - {SWD(2022) 517 final} - {SWD(2022) 518 final} - {SWD(2022) 519 final} - {SWD(2022) 520 final} - {SWD(2022) 521 final} - {SWD(2022) 522 final} - {SWD(2022) 523 final} - {SWD(2022) 524 final} - {SWD(2022) 525 final} - {SWD(2022) 526 final}  
 
 
ABSTRACT 

An  all-party  Committee  of  Inquiry  has  been,  since  2020,  examining  how  to  strengthen  the 
independence  of  the  judiciary  in  Sweden  and  is  expected  to  deliver  its  report  by  February 
2023. The Government has proposed a higher, multi-year budgetary allocation to the Swedish 
courts  in  response  to  an  increased  caseload,  which  has  addressed  some  of  stakeholders’ 
concerns. To further improve the level of digitalisation, a new system of case management of 
criminal  cases  will  be  introduced  in  2022  and  the  Council  on  Digitalisation  of  the  Judicial 
System  has  adopted  a  Strategic  Plan  for  2023-2027.  Even  though  the  number  of 
administrative cases continues to rise, the efficiency of the Swedish justice system has been 
maintained.  

As in previous years, Sweden’s perceived corruption levels  remain among the lowest in the 
EU  and  the  world.  Transparency  is  the  cornerstone  of  Sweden’s  anti-corruption  approach. 
Some  anti-corruption  related  legal  provisions  are  under  review.  An  interim  report  in  the 
framework of the National Anti-Corruption Plan for 2021-2023 from the Agency for Public 
Management  showed  that  most  institutions  have  corruption  prevention  tools  in  place, 
although  additional  work  remains.  Institutions  fighting  corruption  are  generally  well 
resourced. Corruption related to infiltration of organised crime groups into the public service 
and/or licit economy is a concern. Rules on ‘revolving doors’ cover top executive functions 
in the Government, but are overall limited in scope. The Government launched an inquiry to 
evaluate  these  rules  in  June  2022  which  should  be  completed  by  August  2023.  The 
Government is updating the overall Ethical Guidelines for the Government Offices. Lobbying 
continues to be unregulated. Foreign bribery remains an area of concern with only moderate 
levels of prosecution and final judgments, and shortcomings in its legislative definition. 

Sweden  has  a  strong  legal  framework  guaranteeing  media  freedom  and  pluralism  with 
safeguards  stemming  both  from  the  Constitution  and  from  legislation.  No  media-specific 
legislation  concerning  transparency  of  media  ownership  exists  in  Sweden;  however,  the 
Government has proposed amendments to the Radio and Television Act aiming at enhancing 
the  transparency  of  media  ownership.  It  is  reported  that  Swedish  journalists  continue  to 
benefit  from  among  the  most  favourable  working  conditions  in  the  world,  though  online 
harassment  is  on  the  rise.  The  Government  has  taken  further  steps  to  improve  journalists’ 
protection, not least as part of an ongoing review of the protection afforded by criminal law 
to certain vital functions in the society.  

Following  several  extensions  of  the  legislation  empowering  the  Government  to  take  more 
restrictive measures in the context of the COVID-19 pandemic, the legislation in question has 
ceased  to  apply  as  of  April  2022.  The  Parliament  no  longer  relies  on  informal  agreements 
between  the  Speaker  and  the  party  leaders  to  ensure  its  functioning,  and  returned  to  its 
ordinary working procedures in February 2022. The experience of the COVID-19 pandemic 
underlined  the  need  for  a  comprehensive  legal  framework  to  deal  with  similar  severe 
peacetime crises and led to the task for a committee of inquiry to examine a possible need to 
amend  the  Constitution.  A  National  Human  Rights  Institution  has  been  established  and 
commenced its operations in January 2022. The civil society space in Sweden remains open 
and the framework rules under which civil  society organisations operate, notably  related to 
funding,  are  being  reviewed.  While  the  review  has  been  generally  welcomed,  stakeholders 
have  expressed  some  concerns  on  potential  limitations  that  could  have  an  impact  on  civil 
society engagement. 

1 

 
 
RECOMMENDATIONS 

It is recommended to Sweden to: 

  Continue the work of the Committee of Inquiry on strengthening the protection of 

democracy and the independence of the judiciary, taking into account European standards 
on judicial independence.  

  Evaluate the scope, impact and implementation of the rules relating to revolving doors 

that cover top executive functions in the government. 

  Strengthen the fight against foreign bribery, including through amending existing legal 

definitions and improving on prosecution and final judgments of cases. 

  Ensure  that  on-going  reforms  to  the  legal  framework  for  the  funding  and  operation  of 

civil society organisations do not unduly affect civil society engagement. 

2 

 
 
 
I. 

JUSTICE SYSTEM  

The  Swedish  justice  system  has  two  branches:  the  general  courts,  consisting  of  48  district 
courts,  six  courts  of  appeal  and  the  Supreme  Court;  and  the  administrative  courts  with  12 
administrative  courts,  four  administrative  courts  of  appeal  and  the  Supreme  Administrative 
Court.  There  are  also  two  special  courts1.  The  National  Courts  Administration,  an  agency 
operating  under  the  Ministry  of  Justice,  is  responsible  for  the  overall  management  of  the 
Courts,  including  allocation  of  resources,  staffing  levels  and  equipment.  The  independent 
Judges’  Proposal  Board2  prepares  proposals  for  all  judicial  appointments3,  based  on  which 
judges are appointed by the Government4. The Swedish Prosecution Service5 is independent 
and  separate  from  the  Government.  Sweden  is  undertaking  steps  for  joining  the  European 
Public Prosecutor’s Office (EPPO) as the Government intends to present a government bill to 
the Parliament in 20226. The Swedish Bar Association is an independent and self-governing 
association established by law and is responsible for supervision of the professional activities 
of advocates and taking disciplinary measures against its members7.  

Independence  

The level of perceived judicial independence in Sweden continues to be high both among 
the  general  public  and  companies.  Overall,  74%  of  the  general  population  and  70%  of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  20228.  According  to  data  in  the  2022  EU  Justice  Scoreboard,  no  clear  trend  can  be 
identified in the evolution of the perceived level of independence since 2016. The perceived 
judicial independence among the general public has increased in comparison to 2021 (71%), 
but it remains lower than in 2016 (77%). For companies, the situation is the opposite: it has 
slightly decreased in comparison with 2021 (71%) but is higher than in 2016 (66%). 

The  Committee  of  Inquiry  on  strengthening  the  protection  of  democracy  and  the 
independence  of  the  judiciary  has  continued  its  work  and  will  present  its  report  by 
February 2023.  The all-party committee has been meeting regularly and  has intensified  its 
work,  including  by  setting  up  two  external  expert  groups  to  support  it  in  its  tasks,  one  in 

1   The Labour Court and the Defence Intelligence Court. Input from Sweden for the 2021 Rule of Law Report. 
For a description of the judicial structure, see CEPEJ (2021), Study on the functioning of judicial systems in 
the EU Member States.  

2   The Judges’ Proposal Board is composed of nine  members: five current or former judges proposed by the 
courts, two law  graduates  working outside the court system (one lawyer proposed by the Bar Association, 
the other proposed by the Swedish Association of Local Authorities and Regions and the Swedish Agency 
for Government Employers) and two representatives of the public. The members of the public are appointed 
by Parliament (and are usually members of Parliament), while the seven other members are appointed by the 
Government.  

3   The Judges’ Proposal Board, following an assessment of the applicants’ qualifications, submits a motivated 
proposal  (ranked  list,  in  general  three  candidates)  to  the  Government,  which  appoints  the  judge.  If  the 
Government  intends  to  select  a  candidate  not  included  in  the  proposal  of  the  Judges’  Proposal  Board,  the 
Board  is  to  have  an  opportunity  to  submit  an  opinion  on  the  candidate.  In  practice,  since  2011,  when  the 
current system came into force, the Government has always followed the proposal.  

4   Act on the Appointment of Permanent Judges (2010:1390).  
5   Instrument of Government, Chapter 12, Section 2. 
6   Input from Sweden for the 2022 Rule of Law Report, p. 1. 
7   Code of Judicial Procedure, Chapter 8. 
8   Figures 50 and 52, 2022 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as  follows:  very  low  (below  30%  of  respondents  perceive  judicial  independence  as  fairly  good  and  very 
good); low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 

3 

 
                                                 
relation  to  the  constitutional  amendments  and  another  dealing  with  independence  of  the 
judiciary9.  The  Committee  has  been  carrying  out  comparative  research  on  judicial 
independence  and  constitutional  amendments,  notably  by  looking  at  Member  States  with 
similar characteristics10. It was set up in February 2020 and will deliver its report in February 
202311. Key issues will include the retirement age and number of Supreme Court judges, the 
status and independence of the National Courts Administration and the process for amending 
the Constitution. While this is not part of the  Committee’s mandate, stakeholders have also 
raised the issue of the Swedish Chancellor of Justice, who is appointed by the Government 
and tasked with supervising courts and judges, and initiating disciplinary procedures against 
judges, which could raise concerns in view of judicial independence12. As noted in the 2021 
Rule  of  Law  Report,  salaries  of  newly  appointed  judges  continue  to  be  set  based  on  a 
collective agreement between the judges and the National Courts Administration and within 
this  framework  they  are  revised  annually  between  the  judge  and  the  responsible  Court 
President13.  

Quality  

to 

In  response  to  an  increased  caseload  in  the  Swedish  courts,  the  Government  has 
the  National  Court 
proposed  a  higher,  multi-year  budgetary  allocation 
Administration. In the Budget Bill for 2022, the Government allocated to the Swedish courts 
for  their  activities  in  the  period  2022-2024  approximately  EUR  623  million  (SEK  6.7 
billion)14, which is an increase of almost 5 percent compared to 202115. As noted in the 2021 
Rule of Law Report, the stakeholders and the National Courts Administration had stressed the 
need for increasing the resources on a longer-term instead of a year-by-year basis to ensure 
predictability  and  allow  courts  to  cope  with  increasing  numbers  of  criminal  cases16.  The 
National  Courts  Administration  submitted  to  the  Government  its  response  on  the  proposed 
budgetary allocations on 28 February 2022.  It  has asked for additional resources on certain 
specific allocation items,  including approximately  EUR 10.7 million  (SEK 115 million) for 

9   The  expert  group  examining  the  question  of  constitutional  amendments  is  composed  of  two  professors  of 
political science, a judge of the Supreme  Administrative Court and a former head of the secretariat for the 
Constitution Committee. The expert group that is dealing with the topic of the independence of the judiciary 
is composed of representatives for the Judges’  Association, the Swedish Bar Association and the National 
Courts  Administration,  as  well  as  a  senior  lecturer  of  political  science  and  a  law  professor.  The  inquiry 
committee has also set up a separate group consisting of three justices from each of the two supreme courts, 
which is looking at questions from the committee’s assignment that specifically concern the supreme courts 
(e.g. whether the number of the justices should be regulated in the Constitution). Information received from 
the Secretariat of the inquiry committee.  

10   The  work  of 

the  committee  is  taking  into  account  relevant  European  standards,  in  particular 
Recommendation  CM/Rec(2010)12  of  the  Committee  of  Ministers  of  the  Council  of  Europe  and  relevant 
Venice Commission opinions. See 2021 Rule of Law Report, Country Chapter on the rule of law situation in 
Sweden, p. 3. 

11   See 2020 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, pp. 2-3 for a detailed 
overview of the Committee’s mandate. In March 2021, the Committee delivered a report on the first part of 
its mandate, namely relating to possible restrictions to the freedom of association for terrorist associations.  

12   Contribution from Civil Liberties Union for the 2022 Rule of Law Report, p. 3. 
13   According to the Judges’  Association, there has been no changes on the salary system  in the period under 
observation.  See  also  Rule  of  Law  Report  2021,  Country  Chapter  on  the  rule  of  law  situation  in  Sweden, 
p. 3. 

14   Input  from  Sweden  for  the  2022  Rule  of  Law  Report,  p.  5;  Contribution  from  the  National  Courts 

Administration for the 2022 Rule of Law Report, p. 11.  

15   As noted in the 2021 Rule of Law Report, the allocation in 2020 was approximately EUR 585 million (SEK 

6 billion) and approximately EUR 625 million in 2021 (SEK 6.4 billion).  

16   See 2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 4. 

4 

 
                                                 
the operation of the courts in 202517. While the increased allocation was broadly welcomed 
by stakeholders, the Judges Association pointed out that the increase in allocations to courts 
needs  to  be  compared  with  the  even  greater  increase  of  allocations  to  the  Prosecution 
Authority  and  the  Police18.  The  recruitment  of  judges  is  an  important  challenge  for  the 
Swedish  courts19.  Sweden  has  been  spending  around  0.27%  of  its  GDP  on  law  courts  at  a 
stable level since 2012, and in particular for the period 2018-202020.  

Digitalisation of justice is addressing some of the gaps and the Council on Digitalisation 
of  the  Judicial  System  has  adopted  the  Strategic  Plan  for  2023-2027.  The  use  and 
availability of digital technology in Swedish courts is overall good21. During 2021 more than 
180 000  videoconference  calls  to  and  from  court  rooms  were  made,  which  represents  an 
increase of 40% (127 000 in 2020) 22. However, shortcomings in accessing first instance court 
judgments  online  and  arrangements  for  their  machine  readability  remain23.  While  there  has 
been  some  improvement  on  digital  solutions  to  conduct  and  follow  criminal  proceedings, 
notably  concerning  the  possibility  for  victims  and  defendants  to  submit  written  statements 
online, the available digital tools remain limited24. The digital case management of criminal 
cases at first instance will be operational by the end of September 202225. The new system for 
digital  court  judgments  in  criminal  proceedings  is  expected  to  lead  to  significant 
improvements in the accessibility to first instance digital court judgments and their machine 
readability26.  After  the  completion  of  that  project  in  autumn  2022,  the  system  will  be 
gradually  integrated  with  other  authorities  and  developed  to  handle  also  other  types  of 
proceedings and judgments27. In February 2022, the Council on Digitalisation of the Judicial 
System28 adopted the new Strategic Plan for Digitalisation of the Judicial System for 2023-
202729.  That  Plan  focuses  on  joint  efforts  between  the  authorities  and  cooperation  on 

17   National Courts Administration (2022) Budget Support 2023-2025, pp. 7-9. 
18   Opinion published in Svenska Dagbladet (2022), Unstable funding hits court, and information received from 

the Judges Association in the context of the virtual country visit to Sweden. 

19   National  Courts  Administration  (2022)  Budget  Support  2023-2025,  p.  7.  The  Judges  Association  has  also 

referred to problems with filling vacancies in certain courts the during the country visit. 

20   Figure 35, 2022 EU Justice Scoreboard.  
21   Figures 42 and 43, 2022 EU Justice Scoreboard. 
22   Contribution from the National Courts Administration for the 2022 Rule of Law Report, p. 12. 
23   Figures 48 and 49, 2022 EU Justice Scoreboard. 
24   Figure 47, 2022 EU Justice Scoreboard.  
25   This  project  involves  the  development  of  a  new  judgment  in  criminal  cases  with  a  structured  information 
flow throughout the legal chain, electronic signature of the judgment, digital original judgments and built-in 
data protection. National Courts Administration (2022), Annual report 2021, p. 89. 

26   Written contribution from the  National Council for Crime Prevention in the context of the  country  visit to 

Sweden. 

27   Written contribution from the  National Council for Crime Prevention in the context of the  country  visit to 

Sweden. 

28   A Secretariat to the Council was set up within the structure of the National Council for Crime Prevention in 
September  2020.  The  Council  consists  of  the  heads  of  eleven  different  authorities:  National  Council  for 
Crime  Prevention,  Crime  Victim  Compensation  and  Support  Authority,  National  Courts  Administration, 
Economic Crime Authority, Prison and Probation Service, Coast Guard, Police, National Board of Forensic 
Medicine, Tax Agency, Customs  Authority and Prosecution Authority. See also 2021 Rule of Law  Report, 
Country Chapter on the rule of law situation in Sweden, p. 4. 

29   The  different  authorities  within  the  judiciary  have  their  own  individual  strategic  plans  and  strategies  for 
digitalisation  that  exist  in  parallel  to  the  new  strategic  plan.  The  previous  strategic  planning  phase  of  the 
cooperation on digitalisation of the judiciary will be concluded in 2022. By the end of that phase, all major 
information flows between the authorities within the criminal proceeding process will have been digitalised. 
Written contribution from the  National Council for Crime Prevention in the context of the  country  visit  to 
Sweden. 

5 

 
                                                 
digitalisation of the judiciary; a roadmap will further outline the main activities and initiatives 
to implement the plan’s strategic goals30.  

Efficiency 

Notwithstanding  a  continued  increase  in  the  number  of  administrative  cases,  the 
efficiency of the Swedish justice system is maintained. The number of incoming civil and 
commercial  litigious  cases  has  remained  comparatively  low  in  2020,  while  incoming 
administrative cases have continued their rising trend31. However, the estimated time needed 
to resolve administrative cases at first instance is short (107 days in 2020) and has continued 
to  decrease  (125  days  in  2019)32.  The  clearance  rate  has  improved  for  both  civil  and 
commercial litigious  cases (from 97.5% in  2019  to  102.8%  in 2020) and  for administrative 
cases (from 101.7% in 2019 to 102.3% in 2020)33. The number of pending civil, commercial, 
administrative and other cases in 2020 remains comparatively low and has slightly decreased 
compared to 201934. In general, the courts have continued to remain open during the COVID-
19  pandemic  and  decisions  on  postponing  hearings  were  taken  at  the  level  of  individual 
courts.  According  to  the  National  Courts  Administrations  data35,  the  rate  of  postponed 
hearings has overall decreased  in 2021 (being at 19.9% in 2021 compared to an average of 
20.9% in 2020)36.  

Sweden  has  introduced  new  rules  aimed  at  improving  the  efficiency  of  its  court 
procedures.  In November 2021, the Code of Judicial  Procedure was  amended to  allow the 
courts  to  decide  certain  criminal  and  civil  cases  without  a  hearing37.  The  aim  of  the 
amendment was to  improve the efficiency in  handling and deciding  cases, while respecting 
the  rights  of  the  parties38.  In  addition,  since  October  2021,  a  pilot  scheme  for  fast-track 
criminal  legal  proceedings  was  extended  to  27  of  the  48  district  courts,  including  six  of 

30   The strategic plan foresees four strategic goals, namely: a digital and structured information flow throughout 
the criminal proceeding process, the communication with natural and legal persons is digital and coordinated 
where relevant, the right digital preconditions for following up and analysing the judiciary, and an efficient 
cooperation that supports innovation. Written contribution from the  National Council for Crime Prevention 
in the context of the country visit to Sweden. 
31   Figures 3 and 5, 2022 EU Justice Scoreboard. 
32   Figure 9, 2022 EU Justice Scoreboard. 
33   Figures 12 and 13, 2022 EU Justice Scoreboard.  
34   Figure 14, 2022 EU Justice Scoreboard.  
35   According to the National Courts Administration’s data, in 2021 the number of incoming and decided cases 
has  slightly  decreased  (by  2,3%  for  incoming  and  1,9%  for  decided  cases  compared  to  2020),  while  the 
number of cases pending at end of the year has continued to decrease (158 245 in 2021 compared to 164 499 
in  2020).  The  Supreme  Court  saw  the  highest  increase  in  percentage  for  incoming  cases,  with  a  16  % 
increase from 2020 to 2021 (6 982 cases in 2020 compared to 8 113 cases in 2021) and a 29% increase in 
cases  pending  at  end  of  year  (1 041  cases  in  2020  compared  to  1 346  cases  in  2021).  National  Courts 
Administration (2022), Annual report 2021, pp. 16, 17 and 19. 

36   National Courts Administration (2022), Annual report 2021, p. 83. The figure for cancelled hearings reports 
the  proportion  of  cancelled  meetings  in  relation  to  total  number  of  meetings  for  all  Swedish  courts.  The 
figures per court may vary significantly. 

37   Swedish Government (2021), Extended possibilities to decide cases on the merits in the general courts.  
38   In criminal cases, the District Courts may decide a case without a hearing if the sentence is not more severe 
than a  fine or a conditional sentence combined with a  fine. Previously it was only possible if the sentence 
was a fine. The court must still arrange a hearing at the request of a party. In civil cases, the Court of Appeal 
may decide a case without a hearing if it is unnecessary. Previously the condition was that the hearing was 
manifestly  unnecessary.  The  amendment  aligned  the  rules  concerning  the  civil  procedure  with  the 
corresponding rules on criminal cases in the procedures at the Court of Appeal. Information received from 
the Ministry of Justice in the context of the country visit to Sweden. 

6 

 
                                                 
Sweden’s largest cities39. A special inquiry has proposed to the Government that this practice 
should be made permanent and used in all Swedish courts from January 2023 onwards40. 

II. 

ANTI-CORRUPTION FRAMEWORK  

Sweden  has  the  legislative  and  institutional  framework  to  combat  and  prevent  corruption 
broadly  in  place.  The  National  Anti-Corruption  Unit  is  the  specialised  prosecution  agency 
within the Swedish  Prosecution Authority  responsible for all criminal  investigations related 
to corruption and bribery, including foreign bribery. As part of the Swedish Police Authority, 
the National Anti-Corruption Police Unit is tasked with both investigating corruption crimes 
and  preventing  corruption  by  supporting  different  public  authorities  in  the  drafting  of  anti-
corruption  policies.  The  Special  Investigation  Department  of  the  Police  Authority  handles 
internal  investigations  of  police  officers  and  prosecutors  (including  as  regards  corruption 
offences). The Swedish  Economic Crime Authority organised under the  Ministry of Justice 
has the mandate to investigate and prosecute serious financial crimes, including the recovery 
of  proceeds  of  crime.  Other  agencies,  such  as  the  National  Audit  Office,  the  National 
Competition  Authority,  the  National  Council  for  Crime  Prevention  and  the  Financial 
Intelligence Unit of the Swedish Police, are in charge of the prevention and investigation of 
corruption, and of forensics and auditing.  

The perception among experts and business executives is that Sweden is one of the least 
corrupt countries in the world.  In the 2021 Corruption Perception Index by Transparency 
International,  Sweden  scores  85/100  and  ranks  second  in  the  European  Union  and  fourth 
globally41.  This  perception  has  been  relatively  stable  over  the  past  5  years42.  The  2022 
Special  Eurobarometer  on  Corruption  shows  that  32%  of  respondents  consider  corruption 
widespread  in  their  country  (EU  average  68%)  and  9%  of  respondents  feel  personally 
affected by corruption in their daily lives (EU average 24%)43. As regards businesses, 38% of 
companies consider that corruption is widespread (EU average 63%) and 14% consider that 
that corruption is a problem when doing business (EU average 34%)44. Furthermore, 36% of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 

39   Between January and October 2021, close to 11 000 cases were decided under that scheme, It has also been 
proposed by a special inquiry commissioned that the Government should make this scheme permanent as of 
2023 and used throughout the country. Contribution from the  National Courts Administration for the 2022 
Rule of Law Report, p. 13. 

40   Contribution from the National Courts Administration for the 2022 Rule of Law Report, p. 13. 
41   Transparency  International  (2022),  Corruption  Perceptions  Index  2021,  pp.  2-3.  The  level  of  perceived 
corruption  is  categorised  as  follows:  low  (the  perception  among  experts  and  business  executives  of  public 
sector  corruption scores  above  79);  relatively  low  (scores  between  79-60),  relatively  high  (scores  between 
59-50), high (scores below 50). 

42   In 2017 the score was 84, while, in 2021, the score is 85. The score significantly increases/decreases when it 
changes more five points; improves/deteriorates (changes between 4-5 points); is relatively stable (changes 
from 1-3 points) in the last 5 years. 

43   Special  Eurobarometer  523  on  Corruption  (2022).  The  Eurobarometer  data  on  citizens’  corruption 
perception and experience is updated every second year. The previous data set is the Special Eurobarometer 
502 (2020). 

44   Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022). The Eurobarometer 
data on business attitudes towards corruption as is updated every second year. The previous data set is the 
Flash Eurobarometer 482 (2019). 

7 

 
                                                 
practices  (EU  average  34%)45,  while  43%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 29%)46.  

The  implementation  of  the  first  National  Anti-Corruption  Plan  for  the  public 
administration, adopted in December 2020, is ongoing. The aim of the Action Plan is to 
provide public agencies with tools and best practices on the prevention of corruption47. The 
Plan  has  overall  been  welcomed,  including  by  the  Council  of  Europe’s  Group  of  States 
against  Corruption  (GRECO)48.  Some  stakeholders  had  previously  expressed  concerns, 
including on the absence of provisions on the integrity of top executive functions within the 
Government49 and a lack of clarity and ambition, although some dialogue with civil society 
has taken place since then50. As a major milestone under the National Anti-Corruption Plan, 
the  Agency  for  Public  Management  published  an  interim  report  on  the  Government’s 
corruption prevention policy, surveying 209 governmental authorities. Overall, about 80% of 
the  authorities  have  risk  analysis  related  to  corruption  in  place  and  65%  of  those  surveyed 
have  also  set  up  a  procedure  to  report  irregularities.  The  interim  report  highlights  three 
factors for improvement: the various authorities’ understanding of the concept of corruption, 
the role of the management and the availability of the necessary resources and expertise. The 
Agency will follow-up on the results of the report, in line with the Anti-Corruption Plan, and 
report by the end of 202351.  

Some  legislative  provisions  related  to  anti-corruption  are  under  review.  As  reported  in 
the  2020  and  2021  Rule  of  Law  Reports52,  a  wide  range  of  corruption  offences  are 
criminalised  in  Sweden  and  legislative  reviews  on  some  specific  issues  are  under  way.  A 
committee of inquiry tasked with reviewing the statute of limitations has proposed to extend 
this  statute  as  applied  to  serious  crimes,  including  the  offences  of  ‘gross  taking  of  a  bribe’ 
and  ‘gross  giving  of  a  bribe’  from  10  years  to  15  years.  This  proposal  is  now  under 
consultation  within  the  Government53.  A  committee  of  inquiry  into  corruption  in  the 
gambling  sector  has  also  identified  a  number  of  potential  measures  to  reduce  risks  of 
corruption. Such potential measures include improving the detection of and the fight against 
match-fixing  and  unlicensed  gambling  activities,  as  well  as  reforms  of  the  gambling  and 
money laundering legislation54. 

Institutions  fighting  corruption  are  generally  well  resourced,  while  an  audit  identified 
some  shortcomings  in  the  Economic  Crime  Authority.  While  the  prosecution  and  the 
police  confirmed  that  resources  were  overall  sufficient55,  issues  were  raised  in  the  area  of 
economic crime. The Swedish National Audit Office made a number of critical remarks with 

45   Special Eurobarometer 523 on Corruption (2022).  
46   Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022).  
47   2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 6. 
48   GRECO Fifth Evaluation Round – Compliance Report, recommendation i, paras. 7-11. 
49   GRECO Fifth Evaluation Round – Compliance Report, recommendation i, paras. 7-11. 
50   Information received from Transparency International in the context of the country visit to Sweden. 
51   Agency  for  Public  Management  (2022), Work  against  corruption  is  under  development,  pp.  1-9  and  input 

from Sweden for the 2022 Rule of Law Report, p. 1 and pp. 9-10. 

52   2020 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 5 and 2021 Rule of 

Law Report, Country Chapter on the rule of law situation in Sweden, p. 6. 

53   Input from Sweden for the 2022 Rule of Law Report, pp. 14-15. 
54   Input  from  Sweden  for  the  2022  Rule  of  Law  Report,  p.  12  and  Swedish  Government  (2021),  Measures 

against match-fixing and unlicensed gaming activities, pp. 9-15.  

55   2021  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Sweden,  p.  7  and  information 

received from the Police and Prosecution Service in the context of the country visit to Sweden.  

8 

 
                                                 
regard to  the  functioning of the Economic Crime Authority, in  particular  regarding internal 
control, information  sharing within the organisation  and the management, prioritisation  and 
focus of its activities (including the use of different IT systems, the conduct of investigations 
and  the  prioritisation  of  preventive  activities)56.  The  Authority  indicated  it  has  taken  a 
number  of  measures  to  address  the  shortcomings  since  2020,  which  is  the  last  year  the 
Auditors  examined57.  Data  of  the  National  Council  for  Crime  Prevention  indicates  a  sharp 
increase  in  reported  bribery  cases  in  2021  compared  to  202058.  In  2021,  prosecutions  were 
initiated for 81 bribery-related crimes and 35 convictions were obtained, including two prison 
sentences (both for gross bribery)59. 

Corruption  relating  to  infiltration  of  organised  crime  groups  into  the  public  service 
and/or  licit  economy  is  a  concern.  Several  government  authorities,  in  their  most  recent 
threat assessment, concluded that gaps exist in the fight against organised crime, including as 
regards its influence through corruption on the public sector60. In particular, responsibilities 
spread out over many institutions and a largely trust-based culture combined with a lack of 
control  tools,  make  detection  of  organised  crime  and  links  with  corruption  difficult. 
Authorities  and  businesses  seem  to  be  vulnerable  to  corruption,  criminal  infiltration  and 
unauthorised  influence  linked  to  organised  crime61.  Concerns  at  local  level,  including  a 
reluctance  of  local  officials  to  report  potential  misconduct,  have  also  been  noted62,  in 
particular in the area of social welfare fraud63. The Government has announced an extensive 
inquiry into the issue, to start in 202264. 

Foreign  bribery  remains  an  area  particularly  exposed  to  risks  of  corruption  due  to 
insufficient  legal  provisions  and  enforcement  efforts  to  hold  companies  liable.  Despite 
being  a  global  export  country  and  having  a  high  concentration  of  multinational  companies, 
Sweden’s  efforts  to  prosecute  and  reach  final  judgments  on  foreign  bribery  have  been 
characterised  as moderate65.  The OECD has  repeatedly  urged Sweden to  reform  its laws to 

56   National Audit Office (2021),  The Economic Crime  Authority ‘The work towards the organized economic 

crime’, pp. 5-7. 

57   Information received from the Economic Crime Authority in the context of the country visit to Sweden and 

Economic Crime Authority, Annual Report 2021, pp. 6-7. 

58   Data submitted on bribery includes 309 reported cases of receiving a bribe, 82 reported cases of offering a 
bribe, and 9 reported cases of trading in influence and negligent financing of bribery in 2021 (in total, 400 
reported cases compared to 152 reported cases in 2020).  

59   Official crime statistics of the National Council for Crime Prevention. 
60   Common government authority (2021), Situation assessment of organised crime 2021, p. 3.  
61   Common government authority (2021), Situation assessment of organised crime 2021, p. 3, pp. 22-26. 
62   Ekström,  Anna  (Investigative  Report  for  the  city  of  Göteborg)  (2021),  Is  there  a  culture  of  silence  in 

Göteborg city? and information received in the context of the country visit to Sweden. 

63   Sweden’s  Municipalities  and  Regions  (2021),  Welfare  offences  and  unauthorised  influences,  p.  5:  ‘The 
problem of unauthorized influence seems to be increasing. Sometimes the attempts to influence are linked to 
welfare  crimes,  sometimes  to  other  decisions  made  by  municipal  officials  and  politicians.  The  interviews 
from  officials  who  work  in  socio-economically  vulnerable  areas  show  that  unauthorized  influence  from 
criminals can be present in daily work and lead to self-censorship and a culture of silence. Many officials 
interviewed  describe  this  not  only  in  terms  of  a  work  environment  issue,  but  also  as  a  threat  to  our 
democratic system’. 

64   Svenska  Dagbladet (2021), Government  wants to  map corruption crimes: ‘We  will take  the initiative for a 
broad review of the existence of unauthorized influence on authorities and administrations and also in the 
private sector, says [Minister of Justice] Morgan Johansson’. 

65   According  to  information  retrieved  by  the  National  Anti-Corruption  Unit,  during  2021  it  initiated  two 
preliminary investigations and saw one indictment in foreign bribery cases (and no final decisions in court 
cases);  written  contribution  received  from  the  Prosecution  Authority.  See  also  2021  Rule  of  Law  Report, 
Country Chapter on the rule of law situation in Sweden, pp. 7-8. 

9 

 
                                                 
make  sure  that  companies  that  bribe  foreign  public  officials  to  obtain  advantages  in 
international business are properly investigated and prosecuted66. As noted in the 2021 Rule 
of  Law  Report  and  by  the  OECD  Working  Group  on  Bribery,  it  remains  difficult  to 
successfully attain convictions in cases of foreign bribery due to difficulties with mutual legal 
assistance and the difficulty to  gather evidence in such cases67. The legislative definition of 
foreign bribery continues to have shortcomings68, which remains a concern, in particular due 
to a lack of corporate criminal liability under Swedish law69.  

Sweden relies on a strong culture of transparency in dealing with potential conflicts of 
interests  and  ethical  breaches.  The  fundamental  law,  various  rules  and  codes  of  conduct 
apply to civil servants and decision-makers70. The Government Offices are currently updating 
the  content  and  form  of  the  Ethical  Guidelines,  which  aims  to  increase  access  and  user-
friendliness and raise awareness about existing laws, rules and codes of conduct provisions. 
The  document,  which  would  not  be  legally  binding71,  is  expected  to  be  adopted  before  the 
general elections in September 202272. The proposed overarching guidelines would still lack 
a supervisory mechanism and there is uncertainty to what extent ministers will be subject to 
them,  as  also  noted  by  GRECO  (the  exact  scope  of  the  guidelines  remains  to  be  decided). 
Furthermore, there is currently no training on conflicts of interest for top executive functions, 
nor is there any advisory committee for ethical issues in place73. The authorities are planning 
to present a digital training offer from autumn 2022 onwards74. Overall, it remains unclear if 
the revised guidelines will adequately address the existing fragmentation of rules. 

Public officials’ asset declaration rules remain incomplete. While GRECO welcomed the 
introduction of the amended guidelines on asset declarations for public officials75, its broader 

66   OECD (2019), Sweden must urgently implement reforms to boost the fight against bribery.  
67   OECD  (2017),  OECD  says  Swedish  progress  combatting  foreign  bribery  insufficient  to  warrant  Phase  4 
evaluation, OECD (2019), Sweden must urgently implement reforms to boost the fight against bribery  and 
2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, pp. 7-8, and information 
received in the context of the country visit to Sweden. 

68   Swedish  criminal  law  does  not  allow  for  corporate  criminal  liability,  as  only  natural  persons  can  be  held 
criminally  responsible.  As  such,  neither  Swedish  nor  foreign  companies  can  be  prosecuted.  However,  a 
corporation may be subject to a system of ‘corporate fines’ if a crime has been committed in the framework 
of the company’s operations.  Company profits linked to  foreign bribery cases can be  subject to forfeiture. 
While  the  Swedish  Government  passed  some  revisions  of  the  laws  at  the  end  of  2019  with  the  aim  of 
implementing  OECD  recommendations,  concerns  and  issues  remain  in  practice  to  effectively  obtain  final 
convictions in foreign bribery cases. In addition, the requirement for dual criminality (i.e. the offence must 
be criminally liable under both Swedish and foreign law) hampers prosecution of foreign bribery cases. 
69   In  the  context  of  its  country  specific  monitoring  in  relation  to  the  OECD  Anti-Bribery  Convention,  the 
OECD  has  called  on  Sweden  multiple  times  since  2014  to  address  issues  with  its  framework  on  foreign 
bribery, including as regards corporate criminal liability, dual criminality and others. For a full overview, see 
https://www.oecd.org/daf/anti-bribery/sweden-oecdanti-briberyconvention.htm.  See  also  OECD  (2019), 
Sweden must urgently implement reforms to boost the fight against bribery and information  received in the 
context of the country visit to Sweden. 

70   GRECO Fifth Evaluation Round – Compliance Report, recommendation ii, paras. 13-23. 
71  While the Guidelines will not be legally binding in themselves, the objective of the Ethical Guidelines is to 
put  the  legal  framework  applicable  to  civil  servants  and  decision-makers  in  context  and  give  examples  of 
situations in which certain laws and rules apply. 

72   Information received from the Ministry of Justice and the Agency for Public Management in the context of 
the country visit to Sweden and written contribution received by the Ministry of Justice in the context of the 
country visit to Sweden. 

73   GRECO Fifth Evaluation Round – Compliance Report, recommendation ii and iii, paras. 13-29. 
74   Written contribution received by the Ministry of Justice in the context of the country visit to Sweden. 
75   2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 8. 

10 

 
                                                 
recommendation to introduce a general requirement of declaration of significant liabilities by 
ministers  and  state  secretaries,  as  well  as  by  their  spouses  and  dependents,  remains 
unaddressed76. 

While lobbying remains unregulated in Sweden, the country’s culture of transparency 
and  disclosure  of  information  underpins  its  approach  to  prevent  corruption.  In 
particular,  recommendations  from  GRECO  on  introducing  rules  on  guidance  for  decision-
makers on how to engage with lobbyists and on disclosure of lobbying contacts have not been 
implemented77. No such binding lobbying rules are planned in the near future78. Nevertheless, 
overall, the general culture of disclosure of information to the public, transparency and access 
to information remains the cornerstone in Sweden’s corruption prevention approach79.  

Rules  on  ‘revolving  doors’  that  cover  top  executive  functions  in  the  Government 
continue to be implemented, and an evaluation was launched in June 2022. The rules on 
‘revolving  doors’  cover  ministers,  cabinet  members  and  state  secretaries  who  move  to 
employment and assignments in organisations other than the Government or public sector, as 
well as the financial supervisory authority (Auditor-General)80. The authorities consider that 
it  appears  that  the  law  so  far  has  had  the  appropriate  preventative  effect,  but  that  its 
implementation period has been too short to properly evaluate its functioning81. Nevertheless, 
Sweden’s post-employment rules remain overall limited in scope and impact82. Between the 
entry  into  force  of  the  relevant  rules  in  2018  and  the  end  of  May  2022,  21  notices  by 
ministers  or  state  secretaries  were  made  to  the  Board  for  the  Examination  of  Transitionary 
Restrictions for Ministers and State Secretaries83; however, the Board has not instituted any 
such transitory measures84.  The  Government appointed an inquiry  committee in  June 2022, 
which aims to submit further proposals for transitionary restrictions in the event of a transfer 
from certain employment or assignments in the public sector. The inquiry will also evaluate 
the  existing  rules  on  ‘revolving  doors’  for  top  executive  functions  in  the  government,  and 
should be finalised by the end of 2023.85 

Proper rules on political party financing  are in place. Reporting obligations for political 
parties  are  clearly  defined.  National,  municipal  and  local  political  parties  are  obliged  to 
disclose  the  source  of  their  revenues  but  not  their  expenditure  to  the  Legal,  Financial  and 

76   GRECO Fifth Evaluation Round – Compliance Report, recommendation vii and viii, paras. 46-53. 
77   GRECO Fifth evaluation  Round  – Evaluation Report, paras. 51-52 and GRECO Fifth Evaluation Round  – 

Compliance Report, recommendation v, para. 37. 

78   Written contribution received from the Ministry of Justice in the context of the country visit to Sweden.  
79   See also section III; 2020 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 

10.  

80   2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 8. 
81   Written contribution received from the Ministry of Justice in the context of the country visit to Sweden and 

GRECO Fifth Evaluation Round – Compliance Report, recommendation vi, paras. 40-45. 

82   2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 8. 
83   One in 2018, nine in 2019, two in 2020, two in 2021 and seven in 2022 (until the end of May 2022). 
84   Written contribution received from the Ministry of Justice in the context of the country visit to Sweden and 
Activity  Report  of  the  Board  for  the  Examination  of  Transitionary  Restrictions  for  Ministers  and  State 
Secretaries 2021. 

85  Swedish Government (2022), The Government appoints an inquiry into transitional restrictions after certain 

employments and assignments in the public sector.  

11 

 
                                                 
Administrative  Services  Agency  (Kammarkollegiet)86.  The  Agency  publishes  the  finance 
reports in a timely manner each July for the previous year87. 

A new Whistleblowers Act was adopted in October 2021. The Act aims to transpose the 
EU Whistleblower Directive88 and applies to private and public organisations89. The Agency 
for  Public  Management  has  published  guidelines  to  assist  government  institutions  in 
implementing  the  law90.  Stakeholders  commended  the  scope  of  the  law,  which  will  also 
include  smaller  institutions  and  municipalities,  and  facilitate  the  identification  of  possible 
corruption cases91.  

Risks  of  corruption  related  to  the  COVID-19  pandemic  are  being  assessed.  The  2021 
Rule  of  Law  Report  highlighted  potential  risks  in  the  area  of  public  procurement92.  The 
Government appointed a committee of inquiry in September 2021 to, among others, analyse 
the need for changed and strengthened regulation to prevent incorrect payments and abuse93, 
and  to  increase  the  possibilities  of  prosecuting  suspected  crimes;  the  committee  of  inquiry 
will deliver an interim report by 31 May 202294.   

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

legal  framework  concerning  media  pluralism 

the 
The  Swedish 
Constitution95 and secondary law96. Freedom of expression is guaranteed by the Instrument of 
Government, the Fundamental Law on Freedom of Expression and the Freedom of the Press 
Act. The Swedish media regulator, the Press and Broadcasting Authority, functions according 
to  the  Constitution97  and  the  Radio  and  Television  Act.  The  Government  has  proposed 

is  established  by 

86   Law  (2018:  90)  on  transparency  in  the  financing  of  parties.  See  also  2021  Rule  of  Law  Report,  Country 

Chapter on the rule of law situation in Sweden, p. 9. 

87   Legal, Financial and Administrative Services Agency, Report Revenue. 
88   Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law. 
89   Input from Sweden for the 2022 Rule of Law Report, p. 1 and 11 and written contribution received from the 

Ministry of Justice in the context of the country visit to Sweden. 

90  Information received from the Agency for Public Management in the context of the country visit to Sweden. 
91   Information received from Transparency International in the context of the country visit to Sweden.  
92   2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, pp. 9-10. 
93   In  particular,  criticism  has  been  raised  about  the  role  of  the  Swedish  Agency  for  Economic  and  Regional 
Growth  (Tillväxtverket)  in  paying  out  short-term  support  to  companies  affected  by  the  pandemic  without 
having sufficient safeguards to prevent fraud or the appropriate tools to respond to suspicious cases. While 
fraud  with  short-term  support  funds  appeared  present,  the  Swedish  Agency  for  Economic  and  Regional 
Growth did not have the necessary know-how or tools to either prevent or respond adequately to such cases. 
See  Swedish  Government  (2020),  Assignment  on  the  prevention  of  crimes  linked  to  the  support  measures 
with government financial and socio-economic consequences taken as a result of the new Coronavirus - final 
report, pp.22-23. 

94   Swedish Government (2021), Review of support for short-term work, pp. 1 and 9.  
95   The  Swedish  Constitution  consists  of  four  fundamental  laws:  the  Instrument  of  Government,  the  Act  of 

Succession, the Freedom of the Press Act and, the Fundamental Law on Freedom of Expression. 

96   Radio and Television Act. 
97   Relevant parts of the Constitution: the Instrument of Government and the Fundamental Law on Freedom of 

Expression. 

12 

 
                                                 
amendments to the Radio and Television Act98, which will aim at increasing the transparency 
of media ownership and update the licensing system99.  

Sweden has in place effective regulatory safeguards for the independence of the media 
regulator. The independent Press and Broadcasting Authority100 has an obligation to support 
freedom  of  expression,  diversity,  independence  and  accessibility.  In  accordance  with  the 
Instrument  of  Government,  the  Authority  houses  and  serves  as  a  preparatory  body  for  the 
Swedish  Broadcasting  Commission  and  the  Media  Subsidies  Council,  both  bodies  are 
independent  from  the  Authority  when  acting  in  their  decision-making  capacity.  The  2022 
budget  of  the  Press  and  Broadcasting  Authority  was  increased  by  approximately  EUR 
146 405  (approximately  SEK  1.5  million)101.  The  Media  Pluralism  Monitor  2022  (MPM 
2022) continues to report a very low risk with regard to the independence and effectiveness 
of the Swedish media regulatory authority102. As also confirmed by stakeholders103, Sweden 
has  a  well-functioning  self-regulatory  framework  for  the  media  sector,  which  covers  both 
private and public media104. The system has also a good participation105.  

The  Government  has  taken  steps  to  increase  transparency  of  media  ownership.  The 
Swedish  legal  system  does  not  provide  for  any  media  specific  legislation  concerning 
transparency of media ownership. Therefore the MPM 2022 assesses a medium risk for the 
indicator on transparency of media ownership. Following an assessment in the context of the 
transposition of the Audiovisual Media Services Directive106, the Government has proposed 
amendments  to  the  Radio  and  Television  Act,  which  would  provide  for  the  disclosure  of 
more  information  concerning  media  ownership  for  all  audiovisual  media  and  radio  service 
providers. The additional information includes also the provision of the ownership structure 
and in some cases the corporate identity number. The amendments would be reinforcing the 
requirement of the Radio and Television Act to provide accessible information of the name 
and  contact  details  of  the  service  providers.  Sweden  has  no  sector-specific  legislation  on 
media  concentration107  and  the  market  is  constituted  by  a  high  level  of  concentration, 
particularly in the audiovisual sector108. Due also to the lack of a specific legislation, MPM 
2022 reports a high risk on the indicator for news media concentration109. 

Sweden has in place solid safeguards against governmental or political  interference in 
public  service  media.  Media  independence  for  electronic  media,  such  as  radio  and 

98   Input  by  Sweden  for  the  2022  Rule  of  Law  Report,  p.  19,  and  Swedish  Government  (2021),  Greater 

transparency in the ownership of broadcasters. 

99   Sweden ranks 3rd in the 2022 Reporters without Borders World Press Freedom Index compared to 3rd in the 

previous year. 

100  The  independence  of  the  Swedish  media  regulator  is  stemming  from  the  Constitution  (IG  Chapter  12, 

Section 2). 

101Government  Decision  13  concerning 

the  Swedish  Press  and  Broadcasting  Authority’s  budget, 

https://www.esv.se/statsliggaren/regleringsbrev/?RBID=22410.  
102  2022 Media Pluralism Monitor, country report for Sweden, p. 11.  
103  Information  provided  by  the  Swedish  Media  Publisher’s  association  in  the  context  of  the  country  visit  to 

Sweden 2022. 

104. As reported in the 2020 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 8. 
105  Information provided by the Media Ombudsman in the context of the country visit to Sweden 2022. 
106  As reported in the 2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 11. 
107  General competition rules apply to media concentration and mergers.  
108  As  reported  by  the  Reporters  Without  Borders  country  specifics,  the  Swedish  audiovisual  market  is 
dominated  by  few  players,  four  television  and  three  radio  groups  (this  includes  publicly  owned  media), 
https://rsf.org/en/country/sweden. 

109  2022 Media Pluralism Monitor, country report for Sweden, p. 13.  

13 

 
                                                 
television,  is  guaranteed  by  the  Fundamental  Law  on  Freedom  of  Expression,  both  for  the 
private  and  the  public  media.  Sweden  has  three  public  media  companies:  Swedish  Radio 
(SR),  Swedish  Television  (SVT)  and  Swedish  Educational  Radio  (UR)110.  The  Parliament 
decides  on  the  general  remit,  the  organisational  framework  as  well  as  the  allocation  of 
funding for the three public companies ahead of each new licensing period. This is based on a 
dedicated Government bill, which in turn is based on proposals by a committee of inquiry and 
a  public  consultation.  The  public  media  companies  decide  on  the  operational  fulfilment  of 
such  remit,  without  the  involvement  of  the  Government  or  the  Parliament.  However,  the 
public media companies are required to annually and publicly report on the fulfilment of the 
remit’s  terms  and  conditions.  The  reports  are  assessed  by  the  Broadcasting  Commission111. 
Concerning  the  governance  structure  of  the  public  service  media  companies,  the  owning 
foundation appoints  and  dismisses the members  of  their board of directors,  in  line with  the 
legal system for private limited companies. The foundation has no possibility to influence the 
operation  and  neither  the  foundation  nor  the  members  of  the  boards  can  influence  the 
editorial  decisions  of  the  three  companies.  As  the  appointment  procedures  are  well  defined 
and  provide  for  the  independence  of  the  Swedish  public  service  media  boards  and 
management, the MPM 2022 reports a low risk concerning the indicator for independence of 
public  service  media  governance  and  funding112  Following  some  criticism  to  the  system  of 
pre-assessment  by  the  Government  of  significant  new  services  for  public  service  media, 
mainly concerning its inherent risk of affecting media freedom, the Government has launched 
an inquiry in March 2021 to review the system. The licensing process in Sweden is regulated 
by the Radio and Television Act113. The licensing period for the public media companies was 
recently  extended  to  8  years114.  Further  amendments  to  the  Radio  and  Television  Act  were 
proposed  in  order  to  extend  to  8  years  the  licensing  period  for  the  terrestrial  network  for 
commercial  television,  analogue  and  digital  commercial  radio115.  These  changes  would  set 
more operational independence and predictable conditions for both the public and the private 
companies116. 

A recent inquiry has confirmed that the framework on access to information continues 
to work well. Sweden has a robust framework for access to information117. Following some 
instances in the early stages of the COVID-19 pandemic, where media and the public were 
unable  to  access  decisions  on  the  short-time  work  allowance,  in  2021  the  Government 
launched an independent inquiry to investigate the situation of public’s access to information, 
especially  related  to  the  pandemic.  In  spite  of  identifying  some  examples  of  direct  and 
indirect restrictions, the inquiry findings were overall positive and confirmed that the system 
works well118. The MPM 2022 assesses a low risk on the indicator for the protection of the 

110  The  Swedish  public  service  media  are  private  limited  companies.  They  are  owned  by  a  non-profit 
foundation,  the  Förvaltningstiftelsen  för  Sveriges  Radio  AB,  Sveriges  Television  AB  och  Sveriges 
Utbildningsradio AB. 

111  An independent decision-making body within the Press and Broadcasting Authority. 
112  2022 Media Pluralism Monitor, country report for Sweden, p.15. 
113  Radio and Television Act (2010:696). 
114  Chapter 4, section 12 and Chapter 11, section 4. 
115  Swedish Government (2021), Greater transparency in the ownership of broadcasters. 
116  According to the Swedish authorities, the proposal is foreseen for adoption in July; input from Sweden for 

the 2022 Rule of Law Report. 

117  As assessed in the 2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 11. 
118  Swedish Government (2022), The principle of openness under COVID-19-pandemic.  

14 

 
                                                 
right to information, this is considered a positive change compared to MPM 2021 when the 
risk was higher due to the temporary restrictions for the COVID-19 pandemic119.  

Swedish  journalists  continue  to  work  in  overall  favourable  conditions.  Recurring 
challenges  for  journalists  are  the  declining  numbers  of  permanent  employment,  increased 
threats  and  harassment,  particularly  online;  such  threats  in  particular  could  in  some  cases 
result in self-censorship120. Since July 2021, two alerts have been recorded on the Council of 
Europe  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists121.  The 
MPM  2022  reports  a  low  risk  for  the  indicator  on  the  protection  and  standards  of  the 
journalistic profession, and that journalists continue to  operate under favourable conditions, 
however  it  also  reports  that  Swedish  journalists  are  exposed  to  hatred  and  insults122.  The 
inquiry  chair  appointed  in  2020  to  review  the  criminal  law  protection  for  certain  vital 
functions in society, including journalists123, has completed its assessment and concluded that 
the  journalistic  profession  is  highly  vulnerable  and  therefore  proposed  enhanced  criminal 
protection  for  journalists  and  persons  closely  related  to  them124.  The  Government’s 
assignment  to  the  ‘Fojo  Media  Institute’  to  develop  support  for  journalists  and  editors 
subjected  to  threats  and  hatred  has  been  extended  for  2022125.  As  a  further  step  for  the 
protection  of  journalists,  the  Swedish  Crime  Victim  Authority  received  approximately 
480 000  EUR  (approximately  5  million  SEK)  in  2021  to  carry  out  a  major  information 
campaign  against  online  hate  speech126.  In  2021,  it  was  deemed  unnecessary  to  provide 
specific  media  support  linked  to  the  COVID-19  pandemic.  However,  the  normal  funding 
allocated to media was reinforced in some cases as a consequence of the pandemic127. During 
2021,  the  Government  allocated  in  addition  approximately  EUR  20  million  (SEK  200 
million) to media subsidies128. 

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Sweden  has  a  unicameral,  parliamentary  system  of  governance,  in  which  a  Council  of 
Legislation  ensures  ex-ante  constitutional  review,  while  courts  can  carry  out  an  ex-post 
constitutional review in concrete cases. Legislative proposals can be submitted by Parliament 
or the Government, with the latter submitting the vast majority of proposals in practice. The 
Chancellor  of  Justice,  the  Parliamentary  Ombudsmen,  the  Equality  Ombudsman  and  the 
newly  established  Swedish  Human  Rights  Institute  play  an  important  role  in  the  system  of 
checks and balances and for upholding fundamental rights.  

119  2022 Media Pluralism Monitor, country report for Sweden, p. 10.  
120  Swedish  Government  (2022),  Report  on  the  inquiry  into  enhanced  criminal  law  protection  for  certain 

functions of public benefit and some other criminal matters.  

121  The  alerts  concern  harassments  and  intimidation  of  journalists.  Both  have  been  addressed  by  the  Swedish 
authorities  and  one  of  them  is  an  update  of  an  ongoing  trial.  Council  of  Europe,  Platform  to  promote  the 
protection of journalism and safety of journalists, Sweden.  

122  2022 Media Pluralism Monitor, country report for Sweden, p. 11. 
123  2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 12. 
124  Swedish  Government  (2022),  Report  on  the  inquiry  into  enhanced  criminal  law  protection  for  certain 

functions of public benefit and some other criminal matters.  
125  Input from Sweden for the 2022 Rule of Law Report, p. 19.  
126  Input from Sweden for the 2022 Rule of Law Report, pp. 19 and 20. 
127  In particular by supporting local journalism and reinstating subsidies to free newspapers and the commercial 
radio,  written  contribution  from  the  Swedish  Press  and  Broadcasting  Authority  for  the  2022  Rule  of  Law 
Report, p. 16.  

128  Written contribution from the Swedish Press and Broadcasting Authority for the 2022 Rule of  Law Report, 

p. 16.  

15 

 
                                                 
The  legislation  empowering  the  Government  to  take  more  restrictive  measures  in  the 
context  of  the  COVID-19  pandemic  has  ceased  to  apply.  As  noted  in  the  2021  Rule  of 
Law Report129, in January 2021, the legislative amendments empowering the Government to 
adopt  ordinances  introducing  restrictive  measures  to  combat  the  COVID-19  pandemic130 
entered into force as well as, in July 2020, a temporary act on communicable disease control 
measures  at  eating  and  drinking  establishments131.  The  Constitution  Committee  highlighted 
the ad hoc nature of the legislation, which had entailed disagreement on relevant measures to 
be  included  in  the  framework  and  uncertainty  on  the  appropriate  level  of  decision-making 
between  the  Parliament,  Government  and  administrative  authorities132.  This  legislative 
framework has been extended, first until 31 January 2022133 and then until 31 May 2022134. 
While Parliament approved the extension of this legislative framework until 31 May 2022, it 
also  requested  the  Government  to  return  with  a  proposal  that  the  legislative  framework 
applies  only  until  31  March  2022135.  On  23  March  2022,  the  Parliament  approved  the 
Government's  proposals  to  repeal  the  legislative  framework  with  effect  as  of  1  April  2022 
and  that  the  coronavirus  disease  should  no  longer  be  classified  as  a  danger  to  society  or  a 
threat to public health136. 

A committee of inquiry will examine a possible need for amending the Constitution to 
deal with severe peacetime crises. The experience of the COVID-19 pandemic underlined 
the need for a comprehensive legal framework to deal with future similar crises and allow for 
expedited adoption of legislation137. In the absence of any constitutional provisions on severe 
peacetime  crises  comparable  to  those  on  war  and  threat  of  war  in  Chapter  15  of  the 
Instrument  of  Government,  in  September  2021,  an  all-party  committee  of  inquiry  was 
appointed.  Its  task  is  to  assess  whether  there  is  a  need  to  extend  the  Government’s 
competence  to  take  measures  in  severe  peacetime  crises138.  The  Committee  will  present  its 
report  by  latest  15  November  2023.  In  addition,  a  committee  of  inquiry  was  established  to 
examine the existing disease-prevention legislation and the need for new provisions in view 

129  See 2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, pp. 2-3. 
130  Act (2021:4) on special restrictions to prevent the spread of the disease Covid-19.  
131  Act (2020:526) on communicable disease control measures at eating and drinking establishments. 
132  Information received from the Constitution Committee in the context of the country visit to Sweden. 
133  In approving the extension, the Parliament called on the Government to inform it no later than 12 November 
2021  on  its  views  on  the  continued  validity  of  the  Acts.  If  Parliament’s  Social  Affairs  Committee  would 
have considered that there were no longer grounds for the laws to remain in force, it would take the initiative 
and propose that Parliament repeal them.  Swedish Parliament (2021) Continued validity of the  COVID-19 
law and the law on temporary infection control measures in catering establishments. 

134  Both extensions were subject to a public consultation. While the second extension was also referred to the 

Council of Legislation, the first extension was not. 

135  Swedish Parliament (2022) Continued preparedness through the extension of the validity of the covid-19 law 
and the law on temporary infection control measures in catering establishments;  information received from 
the Constitution Committee in the context of the country visit to Sweden. 

136  Swedish Parliament (2022) COVID-19 Act and Act on temporary communicable disease control measures at 

venues serving food and drink to be repealed. 

137  Input from Sweden for the 2022 Rule of Law Report, p. 21, and information received from the Constitution 

Committee in the context of the country visit to Sweden. 

138  The Committee shall examine a number of aspects, including whether the arrangement of the so-called ’war 
delegation’ is still an appropriate way of organising the work of the Parliament in times of war and threat of 
war; the composition, function and powers of the war delegation; and whether there is a need to extend the 
government's  rule-making  powers  in  serious  peacetime  crises.  The  Committee  can  make  proposals  for 
constitutional and other amendments. Swedish Government (2021) Committee terms of reference – A review 
of  the  regulations  on  the  war  delegation,  where  the  national  meeting  is  held  and  the  government's  norm-
setting powers in serious peacetime crises. 

16 

 
                                                 
of future pandemics with due respect to the fundamental rights and freedoms139. In parallel, 
the  independent  commission  appointed  to  examine  the  Government’s  handling  of  the 
pandemic  in  June  2020  delivered  its  final  and  comprehensive  report  in  February  2022,  in 
which  it  also  noted  difficulties  in  obtaining  documents  from  the  Government140;  the 
Constitution  Committee  issued  clear  criticism  of  the  Government  for  not  providing  that 
commission  with  relevant  documents  and  on  parts  of  its  crisis  management  during  the 
pandemic141.  Measures  taken  in  the  context  of  the  pandemic  have  also  continued  to  be 
reviewed  by  the  Parliamentary  Ombudsmen  based  on  complaints  received142.  The  Supreme 
Administrative Court did not review on substance any cases related to the restrictions linked 
to the COVID-19 pandemic143.  

Following a period of special working conditions due to the pandemic, the Parliament 
has  returned  to  its  ordinary  working  procedures.  On  11  February  2022,  the  Speaker  of 
Parliament  and  the  party  leaders  agreed  to  return  to  the  normal  working  procedures  and 
terminate the special procedures introduced in response to the COVID-19 pandemic144. The 
parliamentary inquiry into how Parliament had functioned during the pandemic presented its 
findings  in  December  2021145.  The  all-party  inquiry  concluded  that  overall  the  Parliament 
was  able  to  work  well  during  the  pandemic,  which  was  to  a  large  extent  due  to  informal 
agreements between the Speaker and the party group leaders. It also noted that the Parliament 
could  consider  adopting  internal  decision-making  rules  for  the  event  of  a  crisis  and  for 
ensuring  a  more  systematic  follow  up  on  the  authorisations  given  to  the  Government  to 
facilitate its handling of a crisis146.  

The opinions of the Council on Legislation have been followed by the Government in a 
majority of cases. The Government is obliged to refer draft legislation in most areas to the 
Council on Legislation, which consists of members from the Supreme Court and the Supreme 
Administrative  Court.  The  examination  by  the  Council  on  Legislation  constitutes  an 

139  Swedish Government (2021) Legislative preparedness for future pandemics. 
140  The report presents a comprehensive analysis of Sweden’s handling of the pandemic in a number of areas. 
Among other, it noted that, to an important extent, already disadvantaged groups have been hardest hit by the 
COVID-19  pandemic.  The  commission  found,  among  other,  that  while  the  choices  on  the  path  for  the 
disease  prevention  and  control,  as  well  as  on  mitigating  the  economic  crisis  were  overall  correct,  the 
measures  taken on disease prevention and control  should  have come  sooner and the Government  ought to 
have  assumed  leadership  on  crisis  management  and  communication  with  the  public.  The  commission  also 
found  that  the  Government  was  overly  dependent  on  assessments  made  by  the  Public  Health  Agency  of 
Sweden, which the commission considered was not a satisfactory arrangement for decision-making during a 
serious crisis in society. Swedish Government (2022), English summary of the final Report - Sweden during 
the pandemic SOU 2022:10, pp. 2-4. 

141  Altinget  (2022),  KU  chairman:  ‘The  government's  handling  of  the  corona  pandemic  is  most  serious’, 

Göteborgs-Posten (2022), KU criticises the Government. 

142  A  high  number  of  complaints,  about  11 500,  concerned  the  introduction  of  vaccination  certificates. 
Parliamentary  Ombudsmen  (2021),  Complaints  to  the  Ombudsmen  about  vaccination  certificates; 
information  received  from  the  Parliamentary  Ombudsmen’s  office  in  the  context  of  the  country  visit  to 
Sweden.  

143  In a  decision of 22 December 2021, the Supreme  Administrative Court rejected an application for judicial 
review  on  the  grounds  that  the  Government's  decision  in  relation  to  the  use  of  vaccination  certificates 
constitutes a normative decision and that it is therefore not subject to judicial review brought by individuals. 
Supreme Administrative Court (2021) Government's decision on vaccination certificate cannot be appealed.  

144  Swedish Parliament (2022) Return to ordinary work procedures for the Riksdag.  
145  Swedish Parliament (2022), The Parliament during the corona pandemic 2020, Inquiry from the Parliament 

Administration 2021/22: URF. 

146  Swedish Parliament (2021) Final report from the Inquiry on the Parliament during the COVID-19 pandemic 

2020. 

17 

 
                                                 
important  ex-ante  constitutionality  check  of  draft  legislation.  The  Government  and  the 
Parliament may choose not to follow its opinion, but courts may take this into account when 
subsequently  assessing  the  norm  in  question147.  In  2021,  the  Government  submitted  123 
legislative  proposals  to  the  Council  on  Legislation  and  the  latter  could  not  endorse  8 
proposals148.  In  one  case  where  the  Council  of  Legislation  could  not  endorse  the 
Government’s  proposal149,  the  Government  nevertheless  submitted  that  proposal  to  the 
Parliament, which adopted it150.  

On 1 January 2022, Sweden had 2 leading judgments of the European Court of Human 
Rights pending implementation151. At that time, Sweden’s rate of leading judgments from 
the  past  10  years  that  remained  pending  was  only  at  13%  and  the  average  time  that  the 
judgments had been pending implementation was 3 years and 1 month152. The oldest leading 
judgment,  pending  implementation  for  6  years,  concerns  the  failure  of  Swedish  courts  to 
exercise jurisdiction in respect of defamation proceedings concerning a television broadcast 
from  a  foreign  country153.  On  1  July  2022,  the  number  of  leading  judgments  pending 
implementation remains at 2154. 

The National Human Rights Institution has commenced work. Following the adoption of 
the law on establishing the National Human Rights  Institution in June 2021155, the Institute 
commenced its activities on 1 January 2022. The independent institute has a broad mandate 
to  monitor,  investigate  and  report  on  how  human  rights  are  respected  and  exercised  in 
Sweden156. While the Institute will not examine individual complaints related to human rights 
violations,  it  will  submit  non-binding  proposals  to  the  Government  for  measures  needed  to 
protect  human  rights157.  The  Institute  is  currently  in  the  process  of  recruiting  further  staff, 
appointing  an  advisory  board  and  mapping  the  human  rights  situation  in  Sweden158.  At  the 

147  2020 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 11.  
148  Information received from the Prime Minister’s Office in the context of the virtual country visit to Sweden. 
149  The Council of Legislation considered the proposal contrary to the generality requirement for legislation laid 
down in the Constitution as it aimed at addressing the outcome of an individual case dealt with by the courts. 
Council on Legislation (2021), Extract from minutes of meeting of 2021/09/16, p. 9. 

150  Swedish Parliament (2021), Government approval of limestone quarries in exceptional cases.  
151  The adoption of necessary execution  measures  for a  judgment by the European  Court of Human  Rights is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 
cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken. 

152  All figures are calculated by the European Implementation Network and are based on the number of cases 
that  are  considered  pending  at  the  annual  cut-off  date  of  1  January  2022.  See  the  Contribution  from  the 
European Implementation Network for the 2022 Rule of Law Report, p. 74.  

153  Judgment of the European Court of Human Rights of 1 March 2016, Arlewin v. Sweden, 22302/10, pending 

implementation since 2016. 

154  Data according to the online database of the Council of Europe (HUDOC). 
155  See also 2021 Rule of Law Report, Country Chapter on the rule of law situation in Sweden, p. 15. 
156  Section  1-2  of  Act  (2021:642)  on  the  National  Human  Rights  Institute  (lag  (2021:642)  om  Institutet  för 

mänskliga rättigheter). 

157  Section  2  of  Act  (2021:642)  on  the  National  Human  Rights  Institute  (lag  (2021:642)  om  Institutet  för 

mänskliga rättigheter). 

158  National  Human  Rights  Institute  (2022),  The  Institute  commences  dialogue  with  civil  society,  and 
information received from the National Human Rights Institute in the context of the country visit to Sweden. 

18 

 
                                                 
earliest  in  2023,  the  Institute  will  be  eligible  to  seek  an  accreditation  under  the  UN  Paris 
Principles159.  

The  framework  rules  on  the  operation  and  funding  of  civil  society  organisations  in 
Sweden  are  being  reviewed.  In  May  2022,  the  Government  submitted  a  proposal  to  the 
Council  of  Legislation160,  which  also  included  introduction  of  so-called  ‘democracy 
conditions’161  to  the  support  from  the  General  Inheritance  Fund  and  to  the  support  for 
religious communities162. Also related to the democracy conditions, the report of the special 
inquiry  into  the  review  of  financial  support  to  civil  society  was  presented  on  21  December 
2021163  and  proposed,  among  other,  a  new  support  function  within  the  Swedish  Centre  for 
Prevention  of  Violent  Extremism  to  assist  decision-making  bodies  that  provide  public 
funding164.  In  November  2021,  the  Government  proposed  an  amendment  to  the  Swedish 
Constitution to extend the possibilities to restrict freedom of association by law in the case of 
associations  that  engage  in  or  support  terrorism,  for  example,  by  means  of  a  broader 
criminalisation  of  participation 
terrorist 
organisations165. In April 2022 the Parliament held the first of the two votes needed166 to pass 
the  amendment  to  the  Constitution.  Civil  society  organisations  expressed  concern  that  the 
amendment could enable undue interference with the freedom of association167. In a parallel 

terrorist  organisation  or  a  ban  on 

in  a 

159  Information received from the National Human Rights Institute in the context of the country visit to Sweden. 
160  Swedish Government (2022), State support to religious communities and democratic conditions.  
161  The democracy conditions aim to prevent distributing public funding to activities which are not compatible 
with society's fundamental values. Swedish Government (2019), Democratic conditions for contributions to 
civil society. 

162  The  General  Inheritance  Fund  is  an  important  source  of  funding  for  organisations  working  with  children, 
young people, persons with disabilities, and older persons. In October 2021, an inquiry report on democracy 
conditions  for  funding  from  the  General  Inheritance  Fund  was  published.  Swedish  Government  (2021), 
Democratic conditions for support from the General Inheritance Fund. Civil society organisations have been 
generally positive, but cautioned against potential risks for civil society engagement, such as a lack of clarity 
on  responsibility  for  action  of  organisations’  representatives  and  the  need  to  preserve  the  organisations’ 
ability  to  engage  in  civil  disobedience.  Franet  (2022), Country research  - Legal environment and space of 
civil society organisations in supporting fundamental rights – Sweden, p. 4.  

163  Swedish Government (2021), Minister of Culture has received the final report from the inquiry into a review 

of support for civil society.  

164  The support function would assist decision-making bodies that provide public funding (e.g. agencies) with 
consultation through in-depth reviews of grant-seeking organisations or other publicly funded activities and 
investigate if there are any connections to violent extremism or other anti-democratic environments in a way 
that  gives  the  decision-making  body  reasons  to  take  special  measures.  Swedish  Government  (2021),  Final 
report of the Inquiry on review of support to civil society, and Swedish Government (2022), Referral SOU 
2021:99, The right recipient – Scrutiny and integrity. As part of the same inquiry, an interim report on issues 
of  personal  data  processing  and  confidentiality  in  cases  of  support  to  civil  society  had  been  published  in 
August  2021.  Swedish  Government  (2021),  Referral  SOU  2021:66  The  right  recipient  –  Democratic 
conditions and integrity. 

165  Swedish  Government  (2021),  Government  proposal  2021/22:42  –  Freedom  of  association  and  terrorist 

organisations.  

166  The  Swedish  Constitution  is  composed  of  four  fundamental  laws.  In  order  to  amend  the  Constitution,  the 
Parliament must adopt two decisions of identical wording with a general election between the two decisions. 
Swedish Parliament (2022), The Constitution. 

167  For example, the National Forum for Voluntary Organizations considers that the  amendment would pose a 
risk  that  organisations  with  democratic  aims  or  individuals  engaged  in  international  oppositional  groups 
could  be  wrongly  classified  as  terrorist  organisations.  Contribution  by  the  National  Forum  for  Voluntary 
Organizations for the 2022 Rule of Law Report (as part of the contribution by the European Civic Forum). In 
their responses on the public consultation,  Amnesty International Sweden and Civil Rights Defenders also 
pointed  out  that  the  proposed  scope  of  the  amendment  could  present  risks  to  impact  also  legitimate  civil 

19 

 
                                                 
 
process, the committee of inquiry on the ban on racist organisations has proposed to ban such 
organisations  through new criminal  legislation168, on which civil  society organisations have 
expressed concerns that it is not well-suited to the objective pursued169. In a separate process, 
the Government had tasked the Swedish Agency for Youth and Civil Society to carry out an 
analysis during a one-year period on the extent and consequences of the harassment, threats 
and violence faced  by civil society organisations.  In its report from  April 2022, the agency 
found  that  more  than  one  in  five  civil  society  representatives  have  at  some  point  been 
subjected  to  violence,  vandalism,  theft,  threats  or  harassment170.  In  order  to  mitigate  the 
impact  of  the  COVID-19  pandemic,  the  Government  proposed  in  February  2022171  an 
enhanced financial support to civil society, notably for child and youth organisation and civil 
society organisations working with particularly vulnerable groups172.  

society activities in the future. See the responses to the Referral of SOU 2021:15 Freedom of association and 
terrorist organisations.  

168  Swedish Government (2021), Government proposal 2021/27 – A ban on racist organisations. 
169  In September 2021, a group of 24 organisations, including Amnesty International Sweden and Civil Rights 
Defenders, came out against the ban of racist organisations. In their view,  it is not possible to design a ban 
that is both strong enough to safeguard the right of all vulnerable groups not to be subjected to racism and 
narrow  enough  not  to  threaten  fundamental  freedoms.  Instead,  they  have  advocated  for  a  better  use  of 
existing  legal  instruments.  Position  published  in  Svenska  Dagbladet  (2021),  No  to  banning  racist 
organisations.  See  also  the  contribution  by  the  National  Forum  for  Voluntary  Organizations  for  the  2022 
Rule of Law Report (as part of the contribution by the European Civic Forum) and contribution by the Civil 
Rights Defenders for the 2022 Rule of Law Report (as part of the contribution by the Civil Liberties Union 
for Europe).  

170  Between October and December 2021, the agency conducted a survey of 4 000 non-profit organisations and 
registered  religious  communities.  The  survey  was  responded  by  43%  of  organisations,  out  of  which  22% 
reported to have been at some time subjected to violence, damage, theft, threats or harassment linked to their 
involvement in the organisation, and 13% in the past year. The report found that most vulnerable are those 
who speak out on LGBTIQ issues (47%), followed by opinions on racism and anti-racism (41%), feminism 
(40%), on religion and beliefs (39%)  or on children and/or young people’s rights (39%).  Swedish  Agency 
for Youth and Civil Society (2022), Unique report from MUCF:  ‘Harassment, threats and violence silence 
civil society’ and Swedish Agency for Youth and Civil Society (2022), Mapping threats and hatred against 
civil society, p. 21. 

171  Swedish Government (2022), Enhanced support to civil society.  
172  Sweden’s  civic  space  remains  ‘open’  according  to  the  rating  by  CIVICUS.  Ratings  are  on  a  five-category 

scale defined as: open, narrowed, obstructed, repressed and closed.  

20 

 
                                                                                                                                                        
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2022 Rule of Law Report 
can  be  found  at  https://ec.europa.eu/info/publications/2022-rule-law-report-targeted-stakeholder-
consultation_en       

Agency  for  Public  Management  (2022),  Work  against  corruption  is  under  development  –  The 
situation picture of the Agency of Public of Management  of the authorities work against corruption 
2021 (Arbete mot corruption är under utveckling - Statskontorets lägesbild av myndigheternas arbete 
https://www.statskontoret.se/publicerat/publikationer/publikationer-
mot 
2021/arbete-mot-korruption-ar-under-utveckling/?publication=true#. 

korruption 

2021) 

Altinget (2022), KU chairman: ‘The government's handling of the  corona pandemic is most serious’ 
coronapandemin  är  mest  allvarligt’) 
(KU:s  ordförande: 
https://www.altinget.se/artikel/kus-ordforande-regeringens-hantering-av-coronapandemin-ar-mest-
allvarligt.  

‘Regeringens  hantering  av 

Board  for  the  Examination  of  Transitionary  Restrictions  for  Ministers  and  State  Secretaries  (2022), 
Activity Report of the Board for the Examination of Transitionary Restrictions for Ministers and State 
Secretaries  2021  (Verksamhetsredogörelse  för  Nämnden  för  prövning  av  statsråds  och  vissa  andra 
befattningshavares övergångsrestriktioner 2021) https://data.riksdagen.se/fil/CD042B32-B108-48F3-
A13A-6DF4E845BDDE. 

Centre  for  Media  Pluralism  and  Media  Freedom  (2022),  Media  pluralism  monitor  2022  –  country 
report on Sweden. 

CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States. 

Civicus, Monitor tracking civic space – Sweden https://monitor.civicus.org/country/sweden/.  

Civil Liberties Union for Europe (2022), Contribution from Civil Liberties Union for the 2022 Rule of 
Law Report.  

Common  government  authority  (2021),  Situation  assessment  of  organised  crime  2021  (Lägesbild 
Organiserad 
2021) 
https://polisen.se/contentassets/5063c5e34f9c4414beb676583eae4ef4/bq_pol045_rapport_myndighete
r-i-samverkan_ta_pf.pdf. 

Brottslighet 

Council  of  Europe:  Committee  of  Ministers  (2010),  Recommendation  CM/Rec(2010)12  of  the 
Committee of Ministers to member states on judges: independence, efficiency and responsibilities. 

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 
Sweden https://fom.coe.int/en/pays/detail/11709586. 

Council on Legislation (2021), Extract from minutes of meeting of 2021/09/16 (Utdrag ur protokoll 
vid 
https://www.lagradet.se/wp-
content/uploads/2021/09/Regeringspr%C3%B6vning-av-kalkstenst%C3%A4kter-i-undantagsfall.pdf. 

sammanträde 

2021-09-16) 

Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law. 

Directorate-General  for  Communication  (2019),  Flash  Eurobarometer  482:  businesses'  attitudes 
towards corruption in the EU. 

Directorate-General for Communication (2020), Special Eurobarometer 502: corruption. 

Directorate-General  for  Communication  (2022),  Flash  Eurobarometer  507:  businesses’  attitudes 
towards corruption in the EU. 

Directorate-General for Communication (2022), Special Eurobarometer 523: corruption. 

Economic  Crime  Authority 
https://www.ekobrottsmyndigheten.se/wp-content/uploads/2022/02/ekobrottsmyndigheten-
arsredovisning-2021-21feb.pdf.  

(2022),  Annual  Report 

(Årsredovisning 

2021 

2021) 

21 

 
Ekström, Anna (Investigative Report for the city of Göteborg) (2021), Is there a culture of silence in 
Göteborg 
Stad?) 
https://goteborg.se/wps/PA_Pabolagshandlingar/file?id=33784.  

Tystnadskultur 

Göteborg 

(Finns 

city? 

Det 

En 

I 

European Civic Forum (2022), Contribution from the European Civil Forum for the 2022 Rule of Law 
Report. 

European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation 
in Sweden. 

European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Sweden. 

European Commission (2022), 2022 EU Justice Scoreboard. 

European Court of Human Rights, judgment of 1 March 2016, Arlewin v. Sweden, 22302/10. 

European Implementation Network (2022), Contribution from the European Implementation Network 
for the 2022 Rule of Law Report. 

Franet, Raoul Wallenberg Institute of Human Rights and Humanitarian Law (2022), Country research 
-  Legal  environment  and  space  of  civil  society  organisations  in  supporting  fundamental  rights  – 
Sweden, Vienna, EU Agency for Fundamental Rights, https://fra.europa.eu/en/publication/2022/civic-
space-2022-update#country-related. 

GRECO  (2019),  Fifth  Evaluation  round  –  Evaluation  Report  on  Sweden  on  Preventing  corruption 
and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law  enforcement 
agencies. 

GRECO (2021), Fifth Evaluation Round – Compliance Report on Sweden on preventing corruption 
and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law  enforcement 
agencies. 

Göteborgs-Posten 
https://www.gp.se/nyheter/sverige/ku-kritiserar-regeringen-1.73988270.  

the  Government 

(2022),  KU 

criticises 

(KU 

kritiserar 

regeringen) 

Legal,  Financial  and  Administrative  Services  Agency,  Report  Revenue  (Redovisa  intäkter) 
https://www.kammarkollegiet.se/vara-tjanster/partiinsyn/redovisa-intakter/det-har-ska-du-redovisa.  

National  Courts  Administration 
https://www.domstol.se/domstolsverket/om-sveriges-domstolar/statistik-styrning-och-
utveckling/arsredovisning/arsredovisning-2021/. 

(2022),  Annual 

report  2021 

(Årsredovisning  2021) 

National  Courts  Administration  (2022),  Budget  Support  2023-2025  (Budgetunderlag  2023-2025) 
https://www.domstol.se/globalassets/filer/gemensamt-innehall/styrning-och-
riktlinjer/budgetunderlag/budgetunderlag_20232025_sverigesdomstolar.pdf. 

National Courts Administration (2022), Contribution from the National Courts Administration for the 
2022 Rule of Law Report. 

National  Council  for  Crime  Prevention  (2022),  Written  contribution  from  the  National  Council  for 
Crime Prevention in the context of the country visit. 

National  Human  Rights  Institute  (2022),  The  Institute  commences  dialogue  with  civil  society 
(Institutet  inleder  dialog  med  civilsamhället)  https://mrinstitutet.se/institutet-inleder-dialog-med-
civilsamhallet/.  

OECD  (2017),  OECD  says  Swedish  progress  combatting  foreign  bribery  insufficient  to  warrant 
Phase 4 evaluation https://www.oecd.org/corruption/oecd-says-swedish-progress-combatting-foreign-
bribery-insufficient-to-warrant-phase-4-evaluation.htm.  

OECD  (2019),  Sweden  must  urgently  implement  reforms  to  boost  the  fight  against  bribery 
https://www.oecd.org/corruption/sweden-must-urgently-implement-reforms-to-boost-fight-against-
foreign-bribery.htm. 

22 

 
Parliamentary  Ombudsmen  (2021),  Complaints  to  the  Ombudsmen  about  vaccination  certificates 
(Anmälningar till JO om vaccinationsbevis (s.k. vaccinpass) https://www.jo.se/PageFiles/33436/9136-
2021.pdf. 

Reporters without Borders – Sweden https://rsf.org/en/country/sweden.  

Prosecution Authority (2022), Contribution from the Prosecution Authority for the 2022 Rule of Law 
Report. 

Supreme  Administrative  Court  (2021)  Government’s  decision  on  vaccination  certificate  cannot  be 
rättsprövas) 
appealed 
https://www.domstol.se/nyheter/2021/12/regeringens-beslut-om-vaccinationsbevis-kan-inte-
rattsprovas/. 

vaccinationsbevis 

(Regeringens 

beslut 

inte 

kan 

om 

Svenska Dagbladet (2021), Government wants to map corruption crimes (Regeringen vill kartlägga 
korruptionsbrotten) https://www.svd.se/regeringen-vill-kartlagga-korruptionsbrotten.  

Svenska  Dagbladet  (2021),  No  to  banning  racist  organisations  (Nej  till  förbud  mot  rasistiska 
organisationer) https://www.svd.se/a/7dVo5W/nej-till-forbud-mot-rasistiska-organisationer.  

Svenska  Dagbladet  (2022),  Unstable  funding  hits  court  (Ryckig  finansiering  slår  mot  domstolar) 
https://www.svd.se/a/OrXmOq/sveriges-domareforbund-ryckig-finansiering-slar-mot-domstolarna. 

Sweden’s Municipalities and Regions (2021), Welfare offences and unauthorised influences – From 
grant fraud to systemic crime (Välfärdsbrott och otillåten påverkan - Från bidragsfusk till 
systemhotande brottslighet) 
https://skr.se/skr/tjanster/press/nyheter/nyhetsarkiv/valfardsbrottettvaxandeproblemikommunerna.587
72.html. 

Swedish  Agency  for  Youth  and  Civil  Society  (2022),  Unique  report  from  MUCF:  ‘Harassment, 
threats  and  violence  silence  civil  society’  (Unik  rapport  från  MUCF:  ‘Trakasserier,  hot  och  våld 
tystar 
https://www.mucf.se/om-oss/pressmeddelanden/unik-rapport-fran-mucf-
trakasserier-hot-och-vald-tystar-civilsamhallet. 

civilsamhället’) 

Swedish Agency for Youth and Civil Society (2022), Mapping threats and hatred against civil society 
(Kartläggning 
samhället) 
hat 
https://www.mucf.se/publikationer/kartlaggning-av-hot-och-hat-mot-det-civila-samhallet. 

civila 

mot 

och 

hot 

det 

av 

National  Audit  Office  (2021),  The  Economic  Crime  Authority  The  work  towards  the  organized 
economic crime (Ekobrottsmyndigheten – arbetet mot den organiserade ekonomiska brottsligheten), 
RIR 
2021:30 
https://www.riksrevisionen.se/download/18.7346a817da1ef2fefc840/1639129041226/RiR_2021_30_
webb.pdf. 

för 

(2019),  Democratic  conditions 

Swedish  Government 
(Demokrativillkor 
dokument/statens-offentliga-utredningar/2019/06/sou-
201935/#:~:text=Demokrativillkor%20f%C3%B6r%20bidrag%20till%20civilsamh%C3%A4llet%20
SOU%202019%3A35&text=Utredningen%20har%20ocks%C3%A5%20tagit%20fram,f%C3%B6rva
ltningsmyndigheter%20i%20till%C3%A4mpningen%20av%20demokrativillkoret. 

to  civil  society 
https://www.regeringen.se/rattsliga-

for  contributions 

civilsamhället) 

bidrag 

till 

Swedish Government (2020), Assignment on the prevention of crimes linked to the support measures 
with government financial and socio-economic consequences taken as a result of the new Coronavirus 
- final report, (Uppdrag om förhindrande av brott kopplade till de stödåtgärder med statsfinansiella 
och  samhällsekonomiska  konsekvenser  som  vidtas  med  anledning  av  det  nya  coronaviruset  – 
Slutrapport)  Ds  2020:28  https://www.regeringen.se/rattsliga-dokument/departementsserien-och-
promemorior/2020/12/ds-202028/. 

Swedish Government (2021), Government proposal 2021/22:42 - Freedom of association and terrorist 
organisations  (Regeringens  proposition  2021/22:42  Föreningsfrihet  och  terroristorganisationer) 
https://www.regeringen.se/4aa59d/contentassets/214be7733f5c404d9eaf701ba3d329a0/foreningsfrihe
t-och-terroristorganisationer-prop.-20212242.pdf. 

23 

 
Swedish  Government  (2021),  Government  proposal  2021/27  -  A  ban  on  racist  organisations  (Ett 
förbud  mot 
https://www.regeringen.se/rattsliga-dokument/statens-
rasistiska  organisationer) 
offentliga-utredningar/2021/05/sou-202127/. 

Swedish Government (2021), Extended possibilities to decide cases on the merits in the general courts 
domstol) 
(Utökade  möjligheter 
https://www.regeringen.se/rattsliga-dokument/lagradsremiss/2021/06/utokade-mojligheter-att-avgora-
mal-pa-handlingarna-i-allman-
domstol/#:~:text=I%20syfte%20att%20brottm%C3%A5l%20i,kraft%20den%201%20januari%20202
2. 

avgöra  mål 

handlingarna 

allmän 

att 

på 

i 

Swedish Government (2021), A review of the regulations on the war delegation, where the national 
meeting is held and the government's norm-setting powers in serious peacetime crises (En översyn av 
regleringen  om  krigsdelegationen,  var  riksmötet  hålls  och  regeringens  normgivningskompetens  i 
allvarliga 
https://www.regeringen.se/rattsliga-
dokument/kommittedirektiv/2021/10/dir.-202180/. 

fredstida 

kriser) 

Swedish Government (2021), Democratic conditions for support from the General Inheritance Fund 
(Demokrativillkor 
stöd  ur  Allmänna  arvsfonden)  https://www.regeringen.se/rattsliga-
dokument/departementsserien-och-promemorior/2021/10/demokrativillkor-for-stod-ur-allmanna-
arvsfonden/.  

för 

Swedish  Government  (2021),  Final  report  of  the  inquiry  on  review  of  support  to  civil  society 
(Slutbetänkande 
civilsamhället) 
om 
https://www.regeringen.se/4b00b6/contentassets/4253a600b18b4e48935ec6a83673fcf0/ratt-
mottagare--granskning-och-integritet-sou-202199.pdf. 

av  Utredningen 

granskning 

stöd 

till 

av 

Swedish  Government  (2021),  Greater  transparency  in  the  ownership  of  broadcasters  (Ökad  insyn  i 
ägandet 
https://www.regeringen.se/rattsliga-
och 
dokument/lagradsremiss/2022/05/okad-insyn-i-agandet-av-radio--och-tv-foretag/. 

tv-företag) 

radio- 

av 

2022 

concerning 

Swedish  Government  (2021),  Government  Decision  13,  Appropriation  directions  for  the  financial 
Authority 
year 
the 
https://www.esv.se/statsliggaren/regleringsbrev/?RBID=22410.Swedish 
(2021) 
Legislative  preparedness  for  future  pandemics  (Författningsberedskap  inför  framtida  pandemier) 
https://www.regeringen.se/rattsliga-dokument/kommittedirektiv/2021/09/dir-
202168/#:~:text=2021%3A68&text=En%20s%C3%A4rskild%20utredare%20ska%20se,register%20
%C3%B6ver%20nationella%20vaccinationsprogram%20m.m. 

Broadcasting 

Government 

Swedish 

Press 

and 

Swedish  Government  (2021),  Measures  against  match-fixing  and  unlicensed  gaming  activities 
(Åtgärder mot matchfixning och olicensierad spelverksamhet) https://www.riksdagen.se/sv/dokument-
lagar/dokument/departementsserien/atgarder-mot-matchfixning-och-
olicensierad_H9B429#:~:text=Statsr%C3%A5det%20Ardalan%20Shekarabi%20beslutade%20den,sp
elverksamhet%20(Fi2020%2F04771.  

Swedish Government (2021), Minister of Culture has received the final report from the inquiry into a 
review  of  support  for  civil  society  (Jeanette  Gustafsdotter  har  tagit  emot  slutbetänkandet  från 
Utredningen 
civilsamhället) 
https://www.regeringen.se/pressmeddelanden/2021/12/jeanette-gustafsdotter-har-tagit-emot-
slutbetankandet-fran-utredningen-om-granskning-av-stod-till-civilsamhallet /.  

granskning 

stöd 

om 

till 

av 

Swedish Government (2021), Referral SOU 2021:66 The right recipient – Democratic conditions and 
integritet) 
(Remiss  av  SOU  2021:99  Rätt  mottagare  –  Demokrativillkor  och 
integrity 
https://www.regeringen.se/remisser/2021/08/remiss-av-sou-202166-ratt-mottagare-demokrativillkor-
och-integritet.  

Swedish  Government  (2021),  Referral  of  SOU  2021:15  Freedom  of  association  and  terrorist 
terroristorganisationer) 
organisations 
https://www.regeringen.se/remisser/2021/03/remiss-av--sou-202115-foreningsfriheten-och-
terroristorganisationer/. 

2021:15  Föreningsfrihet 

(Remiss 

SOU 

och 

av 

24 

 
Swedish  Government  (2021),  Review  of  support  for  short-term  work  (Översyn  av  stödet  vid 
korttidsarbete), 
https://www.regeringen.se/rattsliga-
dokument/kommittedirektiv/2021/09/dir.-202179/. 

2021:79 

Dir. 

Swedish  Government  (2022),  English  summary  of  the  final  Report  -  Sweden  during  the  pandemic 
2022:10) 
Sverige 
SOU 
https://coronakommissionen.com/publikationer/slutbetankande-sou-2022-10/. 

(Slutbetänkande 

pandemin 

2022:10 

under 

SOU 

– 

Swedish  Government  (2022),  Enhanced  support  to  civil  society  https://www.government.se/press-
releases/2022/02/enhanced-support-to-civil-society/.  

Swedish Government (2022), Input from Sweden for the 2022 Rule of Law Report. 

Swedish  Government  (2022),  Referral  SOU  2021:99  The  right  recipient  –  Scrutiny  and  integrity 
integritet) 
Rätt  mottagare 
(Remiss 
https://www.regeringen.se/remisser/2022/02/remiss-av-sou-202199-ratt-mottagare---granskning-och-
integritet/.  

–  Granskning 

2021:99 

SOU 

och 

av 

Swedish Government (2022), Report on the inquiry into enhanced criminal law protection for certain 
functions of public benefit and some other criminal matters (En skärpt syn på brott mot journalister 
och 
funktioner) 
vissa 
https://www.regeringen.se/48fcea/contentassets/ae9ead6e3d7341c3aaefdb1012238e79/en-skarpt-syn-
pa-brott-mot-journalister-och-utovare-av-vissa-samhallsnyttiga-funktioner-sou-20222.pdf. 

samhällsnyttiga 

utövare 

av 

Swedish  Government  (2022),  State  support  to  religious  communities  and  democratic  conditions 
(Statens 
trossamfund  och  demokrativillkor)  https://www.regeringen.se/rattsliga-
dokument/lagradsremiss/2022/05/statens-stod-till-trossamfund-och-demokrativillkor/. 

stöd 

till 

Swedish  Government 
(Offentlighetsprincipen 
dokument/departementsserien-och-promemorior/2021/12/ds-202135/.  

(2022),  The  principle  of  openness  under  COVID-19-pandemic 
https://www.regeringen.se/rattsliga-

covid-19-pandemin) 

under 

Swedish Government (2022), The Government appoints an inquiry into transitional restrictions after 
certain  employments  and  assignments  in  the  public  sector  (Regeringen  tillsätter  utredning  om 
övergångsrestriktioner  efter  vissa  anställningar  och  uppdrag 
i  offentliga  verksamheter), 
https://www.regeringen.se/pressmeddelanden/2022/06/regeringen-tillsatter-utredning-om-
overgangsrestriktioner-efter-vissa-anstallningar-och-uppdrag-i-offentliga-verksamheter/. 

Swedish Ministry of Justice (2022), Written contribution received from the Ministry of Justice in the 
context of the country visit. 

Swedish  Parliament  (2021),  Continued  validity  of  the  covid-19  law  and  the  law  on  temporary 
infection control measures in catering establishments (Fortsatt beredskap genom förlängd giltighet av 
covid-19-lagen 
serveringsställen) 
https://www.riksdagen.se/sv/dokument-lagar/arende/betankande/fortsatt-beredskap-genom-forlangd-
giltighet-av_H901SoU9. 

smittskyddsåtgärder 

tillfälliga 

lagen 

och 

om 

på 

the  Committee  on 

Swedish Parliament (2021), Government approval of limestone quarries in exceptional cases – Report 
of 
the  Environment,  Public  Health  and  Food  Safety  2021/22:MJU7 
(Regeringsprövning  av  kalkstenstäkter  i  undantagsfall,  Miljö-  och  jordbruksutskottets  betänkande 
2021/22:MJU7)  https://www.riksdagen.se/sv/dokument-lagar/arende/betankande/regeringsprovning-
av-kalkstenstakter-i_H901MJU7. 

Swedish  Parliament  (2021),  Final  report  from  the  Inquiry  on  the  Riksdag  during  the  COVID-19 
pandemic  2020  https://www.riksdagen.se/en/news/2021/dec/3/final-report-from-the-inquiry-on-the-
riksdag-during-the-covid-19-pandemic-2020/. 

Swedish  Parliament  (2021),  The  Parliament  during  the  corona  pandemic  2020,  Inquiry  from  the 
Parliament  Administration  2021/22:  URF  (Riksdagen  under  coronapandemin  2020,  Utredning  från 
Riksdagsförvaltningen 
https://www.riksdagen.se/sv/dokument-
lagar/dokument/utredning-fran-riksdagsforvaltningen/riksdagen-under-coronapandemin-
2020_H9A5URF1.  

2021/22:URF) 

25 

 
Swedish  Parliament  (2022),  COVID-19  Act  and  Act  on  temporary  communicable  disease  control 
measures 
repealed 
food 
https://www.riksdagen.se/en/news/2022/mar/23/covid-19-act-and-act-on-temporary-communicable-
disease-control-measures-at-venues-serving-food-and-drink-to-be-repealed/. 

serving 

venues 

drink 

and 

be 

at 

to 

Swedish  Parliament  (2022),  Continued  preparedness  through  the  extension  of  the  validity  of  the 
covid-19 law and the law on temporary infection control measures in catering establishments (Fortsatt 
beredskap genom förlängd giltighet av covid-19-lagen och lagen om tillfälliga smittskyddsåtgärder på 
serveringsställen) https://www.riksdagen.se/sv/dokument-lagar/arende/betankande/fortsatt-beredskap-
genom-forlangd-giltighet-av_H901SoU9. 

Swedish  Parliament 
https://www.riksdagen.se/en/news/2022/feb/11/return-to-ordinary-work-procedures-for-the-riksdag/. 

to  ordinary  work  procedures 

(2022),  Return 

the  Riksdag 

for 

Swedish  Parliament 
works/democracy/the-constitution/. 

(2022),  The  Constitution  https://www.riksdagen.se/en/how-the-riksdag-

Swedish  Press  and  Broadcasting  Authority  (2022),  Contribution  from  the  Swedish  Press  and 
Broadcasting Authority for the 2022 Rule of Law Report. 

Transparency International (2022), Corruption Perception Index 2021 
https://www.transparency.org/en/cpi/2021. 

26 

 
 
 
Annex II: Country visit to Sweden 

The Commission services held virtual meetings in February 2022 with: 

  Agency for Public Management 
  Civil Rights Defenders 
  Committee of Inquiry on Independence of Courts 
  Council on Legislation 
  Economic Crime Authority 
  Ministry of Culture 
  Ministry of Finance 
  Ministry of Health and Social Affairs 
  Ministry of Justice 
  National Courts Administration 
  National Forum for Voluntary Organisations  
  National Human Rights Institute 
  Office of the Parliamentary Ombudsmen 
  Office of the Prime Minister 
  Press and Broadcasting Authority 
  Media Ombudsman 
  Prosecution Service 
  Secretariat of the Constitution Committee  
  Supreme Administrative Court 
  Supreme Court 
  Swedish Association of Judges 
  Swedish Bar Association 
  Swedish Journalists’ Association 
  Swedish Media Publishers’ Association 
  Swedish public radio (SVR) 
  Swedish public television (SVT) 
  Transparency International Sweden 

* The Commission also met the following organisations in a number of horizontal meetings:  

  Amnesty International  
  Article 19  
  Civil Liberties Union for Europe 
  Civil Society Europe  
  European Centre for Press and Media Freedom  
  European Civic Forum 
  European Federation of Journalists  
  European Partnership for Democracy 
  European Youth Forum 
  Free Press Unlimited 
  Human Rights Watch  
 
 
 
  Open Society European Policy Institute (OSEPI) 
  Osservatorio Balcani e Caucaso Transeuropa  
  Philea 

ILGA Europe 
International Federation for Human Rights (FIDH) 
International Press Institute 

27 

 
 
  Reporters Without Borders 
  Transparency International Europe 

28